Student Data Privacy Agreement

Socrates Educational Platform Effective Date: March 11, 2026 Last Updated: March 11, 2026

1. Purpose and Scope

This Student Data Privacy Agreement ("Agreement") describes how the Socrates Educational Platform ("Socrates," "we," "us," or "our") collects, uses, protects, and manages student data. It is intended for parents, guardians, educators, school administrators, and district officials who need to understand our commitment to student privacy before allowing students to use the Platform.

1.1 About Socrates

Socrates is an AI-powered educational platform where students upload homework and assignments, which are analyzed by artificial intelligence to generate interactive learning games, Socratic tutoring sessions, study audio materials, and progress tracking. The Platform is designed for students in 6th grade through high school (approximately ages 11-18) and includes a family model where guardians can oversee their students' learning.

1.2 Scope of This Agreement

This Agreement covers all student data processed by the Socrates Platform, including data provided directly by students, data provided by guardians or schools on behalf of students, and data generated through students' use of the Platform. It supplements our Privacy Policy, Privacy Policy for Kids, and Terms of Service.

1.3 Our Commitment

We believe that student data belongs to students and their families, not to technology companies. We built Socrates to help students learn, and every data practice described in this Agreement serves that single purpose.

2. Data We Collect from Students

2.1 Data Provided by Students or Their Guardians

Data Type	Examples	Why We Collect It
Account information	Name, email address	Required for account creation and magic-link authentication
Grade level	6th grade, 9th grade, etc.	Required to generate age-appropriate educational content
School information	School name, city, state	Optional context for content relevance (not required)
Uploaded homework	Photos of worksheets, scanned documents, typed text	Core to the service: this is what the AI analyzes to generate games
Messages	Communications within family groups	Family communication feature
Avatar customization	Character choices, hair/eye/toga colors, accessories	Cosmetic personalization (part of the rewards system)

2.2 Data Generated Through Platform Use

Data Type	Description	Why We Generate It
AI tutoring conversations	Questions students ask and Socratic guidance provided	Enables continuity in tutoring and guardian oversight
Game performance	Scores, accuracy rates, completion status, time spent	Tracks learning progress and adapts difficulty
Activity data	Login timestamps, session durations, login streaks	Supports engagement metrics and the rewards system
Progress metrics	Subject mastery levels, learning trajectory, escalation patterns	Helps students and guardians understand learning progress
Virtual currency	Socrates Coin (drachma) balances and transaction history	Powers the motivational rewards system

2.3 Data Collected Automatically

Data Type	Purpose	Retention
Session tokens	Maintaining login sessions (encrypted, HttpOnly cookies)	Duration of the session only
IP addresses	Security monitoring and abuse prevention (server logs)	90 days
Device type	Adapting the interface (mobile, tablet, desktop)	Not stored; detected per session

3. Data We Do NOT Collect

We want to be explicit about what we do not do:

No social media data. We do not connect to or collect data from any social media platform.
No advertising profiles. We do not build advertising profiles of students. We do not serve ads. Period.
No data selling. We do not sell, rent, lease, or trade student data to anyone, for any reason, ever.
No third-party tracking. We do not use third-party tracking pixels, analytics services, or advertising networks.
No precise geolocation. We do not track students' physical locations.
No biometric data. We do not collect fingerprints, facial recognition data, or any biometric identifiers.
No behavioral profiling for non-educational purposes. Student activity data is used solely to support learning and the Platform's educational features.
No cross-service data sharing. Student data from Socrates is never combined with data from other services or platforms.
No passwords stored. We use passwordless magic-link email authentication. There are no passwords to leak.

4. COPPA Compliance (Children Under 13)

The Children's Online Privacy Protection Act (COPPA) requires that online services obtain verifiable parental consent before collecting personal information from children under 13. We comply fully.

4.1 Parental Consent Required

Students under 13 cannot create their own accounts. A guardian must create the student's account from within their own authenticated guardian session.
Before creating a student account, the guardian is presented with our full Parental Consent Form detailing exactly what data will be collected and how it will be used.
The guardian must affirmatively consent to each category of data collection.
A confirmation email is sent to the guardian, and the student account enters a 48-hour pending state during which the guardian can revoke consent.
The student account is activated only after the 48-hour window passes without revocation.

4.2 Parental Rights Under COPPA

Parents and guardians of children under 13 have the right to:

Review their child's personal information through the guardian dashboard.
Request deletion of their child's data at any time.
Revoke consent and have the child's account deactivated within 48 hours.
Refuse further collection of their child's data.

To exercise these rights, guardians can use the dashboard settings or email [email protected].

4.3 Minimum Data Collection

For students under 13, we collect only the minimum data necessary to provide the educational service. Optional fields (such as school name) are clearly marked and not required.

5. FERPA Compliance (Educational Records)

The Family Educational Rights and Privacy Act (FERPA) protects the privacy of student education records maintained by schools and educational agencies. When Socrates is used in a school or district context, FERPA applies.

5.1 School Official Designation

When a school or district enters into a Data Processing Agreement with Socrates, we act as a "School Official" with a "legitimate educational interest" under FERPA. This means:

We perform an educational service the school would otherwise perform itself.
We are under the school's direct control regarding use and maintenance of education records.
We use education records only for the authorized educational purpose.
We do not re-disclose student education records to unauthorized third parties.

5.2 Parental and Eligible Student Rights Under FERPA

Under FERPA, parents (and eligible students aged 18+) have the right to:

Inspect and review education records.
Request amendment of records they believe to be inaccurate.
Consent to disclosures of personally identifiable information (with exceptions permitted by FERPA).
File complaints with the U.S. Department of Education's Family Policy Compliance Office.

5.3 No Re-Disclosure

We do not re-disclose student education records to any third party except as authorized by the school's Data Processing Agreement (see Section 10) or as required by law.

6. SOPIPA Compliance (No Targeted Advertising)

The Student Online Personal Information Protection Act (SOPIPA) and similar state laws prohibit operators of educational technology from engaging in certain practices. We comply by design:

No targeted advertising. We do not use student data to target advertisements to students or their families.
No advertising profiles. We do not build profiles of students for advertising purposes.
No sale of student data. We do not sell student information to third parties.
No non-educational commercial use. We do not use student data for any purpose other than providing and improving the educational service.
No amassing profiles. We do not amass student profiles for purposes unrelated to the educational services we provide.

7. Data Retention and Deletion

7.1 How Long We Keep Data

We retain student data only as long as necessary to provide the educational service. Specific retention periods:

Data Type	Retention Period
Account information (name, email)	Lifetime of account + 30 days after deletion
Uploaded homework	1 year after last access by the student
AI tutoring conversations	6 months (rolling deletion)
Game session records	1 year
Activity data (logins, streaks)	1 year
Avatar customization	Lifetime of account
Virtual currency records	Lifetime of account
Server logs (IP addresses)	90 days
Audit logs (anonymized)	3 years

7.2 Right to Delete

Students (aged 13+), guardians, and schools may request deletion of student data at any time by:

Using the account settings within the Platform.
Emailing [email protected] with the subject "Data Deletion Request."

Upon receiving a verified deletion request:

We verify the requester's identity.
We complete deletion within 30 days.
We send email confirmation when deletion is complete.

Deletion includes: account records, uploaded homework, AI conversation logs, game session records, avatar settings, and virtual currency records. Family messages are anonymized (attributed to "Deleted User"). Audit logs are retained for 3 years but anonymized.

7.3 Automated Cleanup

We run automated processes to enforce retention limits. Before deleting substantive content (homework, inactive accounts), we notify guardians 30 days in advance so they can act if needed.

For full details, see our Data Retention Policy (referenced in our Privacy Policy).

8. Data Security Measures

8.1 Technical Safeguards

Encryption in transit: All data is transmitted over HTTPS/TLS, enforced via Cloudflare.
Passwordless authentication: We use magic-link email authentication. No passwords are stored, so none can be stolen.
Role-based access controls: Students see only their own data. Guardians see only their family's data. Administrators have audit-logged access.
Secure sessions: HttpOnly, Secure, SameSite cookies prevent session hijacking.
Content security: All external content flows through a server-side proxy with DOMPurify sanitization and a domain allowlist. Students' browsers never contact third-party sites directly.
No code execution: AI outputs are structured data (JSON definitions), never executable code. There is no risk of malicious code execution from AI responses.
Network isolation: Platform services run in isolated Docker networks.

8.2 Administrative Safeguards

Access to production systems is limited to the Platform administrator.
All administrative actions are logged in an audit trail retained for 3 years.
We maintain an Incident Response Plan with defined breach classification, notification timelines, and forensic procedures.

8.3 Breach Notification

In the event of a data breach affecting student data:

We will notify affected guardians and schools within 72 hours of becoming aware of the breach.
We will provide details about what data was affected, what we are doing to address it, and what steps users should take.
We will cooperate fully with any investigation by schools, districts, or regulatory authorities.

9. Third-Party Services and AI Providers

9.1 How AI Processes Student Data

When a student uploads homework, the content is sent to an AI provider (currently OpenAI or Anthropic, depending on configuration) for analysis. Here is exactly what happens:

What is sent to the AI provider:

The homework content (text extracted from images, or text entered directly).
The student's grade level (for age-appropriate content generation).

What is NOT sent to the AI provider:

Student names.
Student email addresses.
Any other personally identifying information.

How AI providers handle the data:

Both OpenAI and Anthropic operate under API terms that prohibit using API data for model training.
Data sent via API is processed and discarded; it is not stored by the provider beyond the time needed to return a response.
We have selected AI providers specifically for their strong data handling commitments.

9.2 Other Third-Party Services

Service	Purpose	Student Data Accessed
Cloudflare	CDN, DDoS protection, secure tunnel	IP addresses, request metadata (standard infrastructure)
Resend	Email delivery (magic-link login emails)	Student email addresses (for login link delivery only)

No other third-party services receive student data.

9.3 Subprocessor Obligations

All third-party services we use are contractually bound to:

Process data only as we direct.
Implement appropriate security measures.
Not use student data for their own purposes.
Delete or return data upon termination of their agreement with us.

10. School and District Provisions

10.1 Data Ownership

When Socrates is used through a school or district partnership:

The school retains ownership of all student data. Socrates acquires no ownership rights.
The school controls how student data is used, and Socrates acts under the school's direction.
Upon termination of the school relationship, all student data is returned or deleted at the school's election.

10.2 Formal Data Processing Agreement (DPA)

For schools and districts that require a formal, signed Data Processing Agreement, we provide a comprehensive DPA template that covers:

FERPA school official designation
Detailed data collection inventory
Third-party subprocessor disclosures
Security measures
Breach notification obligations
Data retention and deletion on termination
Compliance audit rights
Indemnification

To request a formal Data Processing Agreement for your school or district, contact us at [email protected]. We will work with your legal team to execute a DPA that meets your institutional requirements.

10.3 COPPA Consent in School Context

When a school deploys Socrates for students under 13, the school may provide consent on behalf of parents under COPPA (as permitted by FTC guidance for school-authorized educational technology). In this case:

The school represents it has authority to provide consent.
The school retains the obligation to notify parents about the Platform's data practices.
Socrates relies on the school's consent in lieu of individual parental consent.

10.4 School Audit Rights

Schools and districts with an active DPA have the right to audit Socrates' compliance, including:

Documentation of security measures.
Evidence of data handling practices.
Confirmation of subprocessor compliance.
Access to relevant systems for inspection (with appropriate safeguards).

11. Parental Rights Summary

Regardless of whether your student uses Socrates through a school or independently, you have the following rights:

Right	How to Exercise It
Access your child's data	View all data through the guardian dashboard, or request an export
Review AI interactions	View tutoring conversation logs in the guardian dashboard
Request data correction	Email [email protected] with details of the correction needed
Request data deletion	Use account settings or email [email protected]
Revoke consent (under 13)	Use account settings; account deactivated within 48 hours, data deleted within 30 days
Opt out of optional data	School name and other optional fields can be left blank or removed at any time
Receive breach notification	Automatic; we notify within 72 hours of discovering any breach affecting your child's data
File a complaint	Contact us first at [email protected]; or file with the FTC (COPPA) or U.S. Dept. of Education (FERPA)

12. Contact Information

For any questions about student data privacy, to exercise your rights, or to request a school/district Data Processing Agreement:

Email: [email protected] Subject line for data requests: "Student Data Privacy Inquiry" Website: socrates.ofbwfh.net

We aim to respond to all privacy inquiries within 5 business days.

13. Effective Date and Amendments

13.1 Effective Date

This Agreement is effective as of March 11, 2026.

13.2 How We Handle Changes

If we make material changes to this Agreement, we will:

Update the "Last Updated" date at the top of this document.
Post the revised Agreement on the Platform.
Notify registered guardians by email at least 30 days before the changes take effect.
For schools and districts with active DPAs, notify the designated school contact directly.

Non-material changes (typographical corrections, formatting) may be made without notice.

13.3 Your Continued Use

Continued use of the Platform after the effective date of a material change constitutes acceptance of the updated Agreement. If you do not agree with any changes, you may request deletion of your student's account and data at any time.

14. Related Documents

This Student Data Privacy Agreement reflects our genuine commitment to protecting the students who use Socrates. We built this platform to help kids learn, and we treat their data with the care and respect it deserves.